
4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.

Changes to Qualified Facilities in Texas
Posted: August 20th, 2020
When it comes to a revision of an existing air permit in Texas, the mechanism is primarily determined by the type of permit. For example, a permit-by-rule (PBR) permit usually goes through a revision, whereas a case-by-case permit undergoes an […]
Read articlePennsylvania is Requiring Minor Facilities to Submit Air Emissions Inventories
Posted: August 17th, 2020
In July 2020, the Pennsylvania Department of Environmental Protection (PADEP) revised the instructions for completing annual air emissions inventories for regulated facilities with air permits. The Pennsylvania annual air emissions inventories are more commonly referred to as Air Information Management […]
Read articleFederal Waste Management Standards for Hazardous Waste Pharmaceuticals and P075 Nicotine Listing
Posted: August 17th, 2020
History The U.S. EPA initially proposed to move pharmaceutical wastes – including those regulated as hazardous – into the Universal Waste (UW) program in 2008, but industry concerns over the lack of tracking requirements with the UW program prevented U.S. […]
Read articleDC Updates Air Permit Fees and Adds Synthetic Minor Program
Posted: August 13th, 2020
On June 5, 2020, the District of Colombia Department of Energy and Environment (DOEE) published a long-awaited update to the District of Columbia Municipal Regulations (DCMR) Title 20, Chapters 1-3, which entails revised Air Quality Permit and Emissions Fees and […]
Read articleCAO Permitting Process – you’ve heard of it, you’ve submitted info, but where are you now?
Posted: August 5th, 2020
By now I’m sure you’ve at least heard of the Cleaner Air Oregon (CAO) state health risk-based air toxics regulatory program if you have a Title V, standard, or simple permitted facility in Oregon. Oregon Department of Environmental Quality (ORDEQ) […]
Read articlePFAS Significant New Use Rule (SNUR) – Finalization and “Safe Harbor” Removal
Posted: July 28th, 2020
On June 22, 2020, U.S. Environmental Protection Agency (U.S. EPA) issued a final significant new use rule (SNUR) for a group of long-chain perfluoroalkyl carboxylate (LCPFAC) and perfluoroalkyl sulfonate chemical substances, which include per- and poly-fluoroalkyl substances (PFAS), under the […]
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Aerosols as Universal Waste
Posted: July 28th, 2020
U.S. Environmental Protection Agency (U.S. EPA) finalized the Aerosols as Universal Waste Rule in December 2019 with an effective date of February 7, 2020. Seven states and territories have adopted the new rule as of June 2020, with approximately 11 […]
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Top Ten Air Permitting Tips for New or Expanding Data Centers in Oregon
Posted: July 28th, 2020
Get to Know the Regulators – This is new to them too! In the fall of 2019, an ALL4 data center client began the process of applying for an air permit for a new facility. Being […]
Read articleUpdate on Texas Legislative Session House Bill 2726 – Commencement of Construction
Posted: July 23rd, 2020
The term “commencement of construction” is very important within the context of facility modifications and the potential need to obtain a final permit to construct in advance of actual construction activities. The provisions of House Bill 2726 (HB 2726) if […]
Read articleHow to Navigate Texas Emissions Banking and Trading (EBT) Programs in Houston
Posted: July 22nd, 2020
This is the fourth and final blog in a series where I discuss Texas Emissions Banking and Trading (EBT) Programs specifically in the Houston-Galveston-Brazoria (HGB) region. In this edition, I will discuss different strategies companies can use to get the […]
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